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OSHA Releases New GHS Enforcement Memo

In a memo aimed at field staff who perform workplace safety inspections and issued in September but posted to OSHA’s website recently, OSHA provides useful guidance for chemical industry professionals tasked with maintaining compliance with the updated GHS Hazard Communication Standard, or 2012 HCS.

For employers, the main takeaway from this OSHA guidance may be an answer about re-labeling existing stock of chemical containers. OSHA makes it clear that employers “are allowed to maintain and use those containers with HCS 1994 labels.” As long as the labels are not removed of defaced, 1994 HCS-compliant labels are still acceptable in the workplace. That said, employers are still required to train employees on the new label elements.